Memorandum submitted by the Institution
of Civil Engineers
1. NATIONAL INFRASTRUCTURE
POLICY
1.1 ICE has consistently argued for UK infrastructure
development to be placed on a long term, strategic footing. As
a nation, it is estimated that we will require infrastructure
investment in excess of £400B[88]
in the coming decades to meet a range of policy goals including
improved energy security and the transition to a low carbon economy.
The UK needs political structures that provide stability, clarity
and certainty if investors and clients are to fund and the supply
side develop the capacity to deliver new and refurbished infrastructure
on this scale. In addition as spelt out clearly in recent reports
by ICE[89]
and the Council for Science and Technology[90]
the nation's infrastructure networks are increasingly interdependent
and the risk of systemic failures or capacity constraints needs
to be managed. Energy supply is at the heart of this interdependency.
1.2 ICE has therefore been supportive of
the provisions in the Planning Act 2008 relating to Nationally
Significant Infrastructure projects including the creation of
National Policy Statements (NPS) for. We believe that NPSs also
have the potential to reinforce the benefits of other recent reforms.
The newly formed Infrastructure UK (I-UK) has a remit to assess
the UK's long term infrastructure needs and facilitate their delivery.
Government has also appointed a Chief Construction Advisor, a
role we believe can help improve the flow of information on future
needs to the construction and civil engineering industries. Taken
together this provides an opportunity to create a strategic framework
which successive governments could develop and a series of institutions
for improving delivery.
1.3 The Energy National Policy Statements
can establish the broad need for new infrastructure at a national
level and explain how facilities will contribute to policy goals
including targets for renewable energy generation and carbon dioxide
reduction. This is very welcome as it will remove a major source
of uncertainty, delay and cost. However it is unfortunate that
the Infrastructure Policy Commission has no role in assessing
the impact of the sum of its decisions. In relation to CO2 emissions,
government's position is that the operation of the European Emissions
Trading Scheme will allow the UK to manage the risk of the market
delivering new energy infrastructure that would result in higher
than desirable emissions. However there remains a task of managing
other risks, such as long term resilience and cross network interdependencies.
Similarly there are a number of areas where individual nationally
significant infrastructure assets will require considerable amounts
of associated infrastructure, for example road and rail links
to major power stations and pipelines for Combined Heat and Power
and CCS fitted fossil fuel plants. There is a danger that these
requirements may fall between NPSs or between the Nationally Significant
Infrastructure process and the Town and Country Planning Act.
We believe that Infrastructure UK has the potential to help address
these problems by working alongside the IPC to assess the impact
of its decisions on the long term health and "fit for purpose"
status of energy and other networks.
2. ELECTRICITY,
HEATING AND
TRANSPORT
2.1 The Energy NPS do a good job in clarifying
electricity generation capacity requirements for the period to
2025, including broad direction on the desired mix between renewable
and non renewable sources. However we believe government does
need to come forward with more detailed policy for the heat and
transport sectors. In this context the Committee should note that
heat accounts for 49% of all primary energy consumed in the UK,
the majority of which is derived from gas.
2.2 A transition to a low carbon economy
implies a large scale shift to electrification of heat and transport.
This has significant implications for infrastructure for both
generation and transmission and this does need to be better reflected
in National Policy Statements.
3. SUBJECTIVE
ELEMENTS OF
NPSS
3.1 A number of terms that are open to a
wide degree of interpretation including "good design"
and `economically and technically viable' are used in the energy
NPSs. We would welcome clarity on how they will be used in the
decision making processes of the Infrastructure Planning Commission
(IPC).
4. INITIAL COMMENTS
ON INDIVIDUAL
CATEGORIES OF
ENERGY INFRASTRUCTURE
4.1 Combined Heat and Power: We welcome
the requirement to consider the inclusion of Combined Heat and
Power as a planning consideration for proposals for new power
generation stations. ICE's recent report, Why Waste Heat identified
significant potential for capturing heat lost during electricity
production for use in residential and commercial heating.[91]
4.2 Carbon Capture and Storage: We welcome
the inclusion of a requirement for Carbon Capture Readiness (CCR)
for future fossil fuel power stations. However we note that there
are still many unknowns around Carbon Capture and Storage (CCS)
technology which will only be resolved through the ongoing demonstration
plant process. Minister may therefore need to be willing to amend
NPSs as the demonstrator programme advances to avoid unnecessary
delays in deployment.
4.3 Biomass and Waste Combustion: We welcome
the inclusion of waste and biomass in the Renewable National Policy
Statements. Recovery of energy from waste materials will need
to be a consideration in the development of any long term energy
policy.
January 2010
88 Helm, D, Wardlaw J and Caldecott, B (2009), Delivering
a 21st Century Infrastructure for Britain, Policy Exchange:London. Back
89
ICE (2009) State of the Nation-Defending Critical Infrastructure,
ICE:London. Back
90
Council for Science and Technology (2009) A National Infrastructure
for the 21st Century, HMSO:London. Back
91
ICE (2009) Why Waste Heat. Back
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